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Member Articles


Becoming Less Valuable: S Corporation “Reasonable Compensation” in Light of IRC 199A

Author: Evan Fox, J.D., LL.M. Under Internal Revenue Code (IRC) Section 1366, shareholders of S Corporations report their share of net income as if it were directly earned. Included in the computation of net income is a ...

More tax law changes impacting inbound and Outbound Investment

As a result of the OECD Base Erosion and Profit Shifting (BEPS) project to minimise tax leakage, amendments have been proposed to Double Tax Agreements (“DTA’s”) through use of a Multilateral Instrument (MLI). The ...

Fig leaf for 'naked' cartel

Author: Dieter Hauck Introduction A recently published decision by the Cartel Court demonstrates how a long-term relationship turned into an equally lengthy disagreement, which came to a decisive turning point in t ...

Three things you need to know about 2018’s biggest reported data breach - the Marriott hack

Authors: Katherine Hayes, Partner and Greg Stirling, Senior Associate In 2019 it is almost inevitable that data breaches will continue to increase as more and more companies report significant breaches. The theft o ...

Partnerships and LLCs Need to Revise Their Agreements to Address New Audit Procedures

In August 2018, the U.S. Department of the Treasury issued final Regulations concerning the qualifications, designation, authority, and resignation of the required Partnership Representative under the new Centralized Par ...

Keep On Truckin': New Prime Inc. v. Oliveira

Authors: Jeremy Mittman and Samuel Richman In a blow to the transportation industry, last week, the U.S. Supreme Court ruled that the trucking company, New Prime Inc., cannot compel arbitration in a class action allegin ...

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